Privacy Policy

At a glance

1. Who we are

This Privacy Policy explains how [ENTITY NAME] ([ENTITY ADDRESS]) ("we," "us," "Cllect") collects, uses, and protects your information when you use the Cllect platform (the "Service").

We are the controller of your account data and usage data. For the documents you upload and the e-mails we send and receive on your behalf, we act as a service provider / processor — processing that content on your instructions to provide the Service. We are also the controller of the crowdsourced label-contacts pool (see Section 7).

2. What we collect

2.1 Account data

When you sign up, we collect:

• Your name and e-mail address.
• Your sign-in is your e-mail address plus a one-time code we send to it. We do not store passwords.
• Your per-account Cllect e-mail address (e.g., deals@masterhold.com or <yourname>@masterhold.com).

2.2 Catalogue and release data

Information about your music releases that you enter manually or import through Spotify (see Section 2.4).

2.3 Uploaded documents

Contracts, royalty statements, invoices, and other PDF files you upload to the Service. These are stored in Cloudflare R2 (file storage) and the extracted/structured data is stored in Cloudflare D1 (database).

2.4 Spotify import data

If you use the Spotify catalogue import feature, we receive catalogue data from the Spotify Web API (such as release names, dates, and identifiers). We do not receive your Spotify login credentials. Your use of Spotify is also subject to Spotify's own privacy policy.

2.5 E-mail content

When you use the e-mail features:

• Outbound e-mails: We store the content of e-mails we send on your behalf, including recipient addresses and any attachments.
• Inbound e-mails: We receive replies sent to your Cllect address. We store the content, sender details, and attachments. We auto-forward the reply to your personal e-mail address.
• Third-party correspondents: The e-mail features necessarily involve the names and e-mail addresses of the people you correspond with (e.g., label contacts). We store this information as part of your e-mail threads.

2.6 Usage and security logs

We collect standard technical logs: IP addresses, browser type, pages visited, timestamps, and error logs. These are used for security and to maintain the Service.

2.7 Beta feedback

Any feedback, bug reports, or suggestions you submit during the beta (see Terms of Service, Section 11).

3. How we use your information

We use your information to:

• (a) Provide the Service — store your data, display it to you, send and receive e-mail on your behalf, process your documents.
• (b) AI-assisted extraction — send the content of your uploaded contracts, statements, and invoices to our AI/LLM provider to extract figures, terms, reversion dates, and other structured data. The extracted data is stored in your account. See Section 6.4 for details about the AI provider.
• (c) Send and receive e-mail — send e-mails from your Cllect address at your instruction; receive, process, and forward replies.
• (d) Security — detect and prevent fraud, abuse, and security incidents.
• (e) Support — respond to your questions and requests.
• (f) Improve the Service — analyse usage patterns and feedback to make the Service better. We do not use your uploaded documents or e-mail content to train AI models.

We do not use your information for advertising. We do not sell your personal data.

4. Legal bases for processing

If you are in the EU or UK, our legal bases are: [review — EU/UK applicability and legal basis analysis]

• Contract performance (Art. 6(1)(b) GDPR [model knowledge — verify]): providing the Service you signed up for.
• Legitimate interests (Art. 6(1)(f) GDPR [model knowledge — verify]): security, fraud prevention, and service improvement, where these do not override your rights.
• Consent: where required (for example, for optional features or communications).

5. Who we share your information with

We share your information only with service providers who help us operate the Service. We do not sell or share your data for advertising.

Sub-processors

We require our sub-processors to protect your data and to use it only for the purposes we specify. We do not authorise them to use your data for their own purposes.

AI provider note: When you upload a document for AI-assisted extraction, the content is sent to our AI/LLM provider for processing. To our knowledge, the provider does not use the content to train its models. [verify against provider terms]

6. Where your data is stored

6.1 Your data is stored on Cloudflare infrastructure. Cloudflare operates a global network; your data may be stored in or transit through the United States and other countries. [review — confirm Cloudflare data residency; assess international transfer mechanism for EU/UK users]

6.2 E-mail is processed through Resend's infrastructure. [verify — confirm Resend data location]

6.3 Document content sent to the AI/LLM provider is processed on the provider's infrastructure. [verify — confirm AI provider data location]

7. The crowdsourced label-contacts pool

In short: We maintain a shared directory of label and distributor business contact information (like royalty department e-mail addresses). This is assembled in part from users' activity and is shared across all Cllect users. It is business contact data of third parties, not your personal data, and it stays in the system even after you delete your account.

7.1 What it is. The label-contacts pool is a shared directory of business contact information for music labels and distributors — for example, the e-mail address of a label's royalty department or a distributor's contracts team. This information is gathered in part through the activity of Cllect users — for example, when a label replies to an e-mail sent through the Service, the label's reply address may be added to the pool. [review — confirm whether any other sources feed the pool]

7.2 Why we maintain it. The pool exists to help all Cllect users reach the right contacts at labels and distributors. It is a core part of how the Service works.

7.3 What kind of data it contains. The pool contains business contact data of third parties (labels and distributors) — names, titles, and e-mail addresses of individuals acting in their professional capacity at those organisations. It does not contain the personal data of Cllect users.

7.4 Retention. The label-contacts pool is retained after a user deletes their account. When you delete your account, all of your personal data is removed (see Section 8), but the business contact information in the label-contacts pool remains available to other users.

7.5 Legal basis for the pool. We maintain the pool on the basis of legitimate interest: it is business contact data processed for the purpose of professional communication in the music industry. [review — confirm legal basis; consider whether label contacts in EU/UK jurisdictions may need to be treated as personal data under GDPR, and whether legitimate interest is sufficient]

7.6 If you are a label or distributor contact. If your business contact information appears in the label-contacts pool and you would like it corrected or removed, please contact us at support@masterhold.com. We will review your request and respond within 30 days.

8. How long we keep your data and how deletion works

8.1 Retention. We keep your data for as long as your account is active.

8.2 Account deletion. You can delete your account at any time through your account Settings. The process works as follows:

• (a) You initiate deletion in Settings and confirm through a double confirmation step.
• (b) We notify the operator (by e-mail and in-app admin notification) of your deletion request.
• (c) The operator manually confirms the deletion.
• (d) Upon confirmation, we delete all of your information, including: releases, contracts, royalty statements, invoices, e-mail threads, inbox rows, sessions, and all files stored in Cloudflare R2.

8.3 What is NOT deleted. The crowdsourced label-contacts pool (see Section 7). This is business contact data of third parties, not your personal data.

8.4 Backups. After deletion from live systems, your data may persist in encrypted backups for a limited window until those backups are rotated. [review — confirm backup retention window and document it here]

9. No sale of personal data

We do not sell your personal data. We do not share your personal data for cross-context behavioural advertising or any advertising purpose. If you are a California resident, this statement is intended to comply with the CCPA/CPRA "Do Not Sell or Share" requirement. [review — CCPA applicability during beta; likely below thresholds but confirm]

10. Security

We implement security measures appropriate to the nature of the data we process, including:

• Encryption in transit (HTTPS / TLS). [verify — confirm TLS is enforced across all services]
• Access controls limiting who can access user data.
• Per-account e-mail isolation — each user's Cllect e-mail address and inbox are separate from every other user's. [verify — confirm technical implementation]
• One-time-code sign-in — accounts are accessed with a code sent to the user's e-mail address; no passwords are stored.

No system is perfectly secure. We cannot guarantee absolute security, but we take reasonable steps to protect your data.

11. Your rights

11.1 You have the following rights regarding your personal data:

11.2 To exercise any right, use the relevant feature in Settings or e-mail us at support@masterhold.com. We will respond within 30 days. [review — 30-day SLA; GDPR requires response within one month; CCPA requires 45 days]

11.3 Note for EU and UK users. If you are located in the EU or UK, you may also have rights under the GDPR or UK GDPR, including the right to object to processing, the right to restrict processing, and the right to lodge a complaint with your local data protection authority. [review — full GDPR/UK GDPR rights analysis; confirm applicable supervisory authority language]

11.4 Note for California users. If you are a California resident, you may have additional rights under the CCPA/CPRA, including the right to know what personal information we collect, the right to delete, and the right to opt out of the sale of personal information (we do not sell your data — see Section 9). [review — CCPA applicability during beta]

12. Children

The Service is not intended for anyone under 18 years of age. We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete that data.

13. International transfers

If you are located outside the United States, your data will be transferred to and processed in the United States (and potentially other countries where Cloudflare operates). By using the Service, you consent to this transfer. [review — this consent-based transfer mechanism may not be sufficient under GDPR; evaluate whether SCCs or other transfer mechanisms are needed for EU/UK users]

14. Changes to this Privacy Policy

14.1 We may update this Privacy Policy from time to time. Each version will carry a version number and effective date.

14.2 When we update the policy, you will be asked to re-accept it at your next login before you can continue using the Service.

14.3 If you do not accept the updated policy, you may stop using the Service and request deletion of your account.

15. Contact

Questions or requests regarding your privacy? Contact us at:

E-mail: support@masterhold.com Entity: [ENTITY NAME] Address: [ENTITY ADDRESS]